Foundations Must Remain Alert to Potential Self-Dealing—Part IV
Author: Katherine E. David, J.D..
Source: Volume 18, Number 03, March/April 2019 , pp.3-8(6)
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Abstract:
This article is the last in a series addressing self-dealing transactions, which continue to be a “major issue” in IRS examinations of private foundations. Parts I through III examined the definitions of “disqualified person” and “self-dealing,” and the concept of “correction.” This final installment discusses how excise taxes under IRC §4941 are calculated and reported, considerations that can be used to mitigate the application of IRC §4941, and potential additional adverse consequences of self-dealing transactions.Keywords: Calculating the IRC §4941 Excise Tax; Filing Forms 4720; Mitigation; Madden v. Commissioner; Thorne v. Commissioner; Involuntary Termination
Affiliations:
1: Clark Hill Strasburger.